This privacy policy explains how I store and use the information I collect about you when you employ me, Patricia Galvin, Speech and Language Pathologist, to provide Independent Speech & Language Assessment and Therapy.

In my practice, I have always taken the protection of client data very seriously, and conform with guidelines from both our professional bodies The Irish Association of Speech & Language Therapists and CORU . The information contained within this privacy policy is a requirement of the new General Data Protection Regulation (GDPR) legislation which replaced the Data Protection Act with effect from 25th May 2018.

 

Patricia Galvin, Speech and Language Pathologist in Private Practice complies with her obligations under the General Data Protection Regulation (GDPR) by keeping personal data up to date; by storing (and destroying it) securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.

 

Your personal data is used for the following purposes

To deliver the services that clients have requested;

To contact those clients as necessary in accordance with the services they have requested;

To maintain records.

Individual client data will never be passed to a third party without the express consent of the respective client, always provided that such confidentiality is neither inconsistent with the Pathologist’s own safety or that of the client, the client’s family members or other members of the public, nor in contravention of any legal action or legal requirement.

In accordance with my need to maintain the possibility of access to client data as a result of returning clients or those who may wish to lodge a complaint in respect of our professional services to either our professional body or our insurers (i.e. in all cases perhaps after a long period of time has elapsed), I retain client data for a minimum period of 7 years.

 

What is your lawful basis for processing my data?

Patricia Galvin, Speech and Language Pathologist processes your personal data under the lawful basis of 'legitimate interests' (GDPR Article 6-1-f). As with any healthcare provider, when you employ the services of Patricia Galvin, Speech and Language Pathologist, there is an implied understanding that I will not be able to assess and treat you safely and appropriately unless you or others give me the relevant information to do so.

Additional rules; requiring a higher degree of protection apply to the health information I hold about you because this is classed by law as 'special category' data. Patricia Galvin, Speech and Language Pathologist processes your healthcare data under the lawful basis of 'the provision of health or social care or treatment (GDPR Article 9-2-h). I am legally permitted to store and use your health data, and communicate this with other professionals involved in your care for health-related purposes (assessment, diagnosis, and treatment), because I am bound by the confidentiality rules of our own professional bodies (The Irish Association of Speech and Language Therapists and CORU).

 

 

What data do you collect about me and why?

Patricia Galvin, Speech and Language Pathologist will collect a variety of data which helps assess, diagnose and provide treatment for you. Data may be given by you or other people and can include the following:

·   Personal information e.g. name, address, date of birth

·   Health information e.g. medical history

·   Email addresses

·   Telephone numbers

·   Correspondence e.g. clinical letters and reports, print outs of emails

·   Assessment forms/results

·   Clinical observations

·   Audio recordings

·   Financial information e.g. bank sort code and account number

·   Contact details for family members (*)

 

(*) Please note that the names and contact details about any family member forms part of the data I hold about you so is treated the same in terms of confidentiality and security.

 

Information may be given verbally or in writing by you, your family/carer, your G.P or Medical Consultant, another healthcare professional involved in your care. I have a professional and legal duty to ensure that the information I record about you is relevant to your treatment/care, accurate and up to date, and only used for the purposes for which it was collected. Please help me to keep records up to date by informing me of any changes e.g. you move house, change your telephone number or change your G.P.

Where is my data kept?

Most of your data will be kept in your main clinical file but data about you may also be kept in the following places:

·   Clinical diaries

·   Work mobile phones

·   Electronic devices e.g. work laptop computers

·   Removable media e.g. memory cards, memory sticks

·   Invoices

·   Patricia Galvin, Speech and Language Pathologist bank statements

·   Back up hard drives

 

How is my data secured?

The private practice takes the security of your data very seriously and employ a series of measures to prevent theft, loss, damage or unauthorised access. These measures are checked regularly. All data is stored securely in locked filing cabinets when not in in use. Laptops are password protected and iphones are pin protected. Data is encrypted as an additional security measure, and I use anti-virus software to protect data from cyber-attack.

Who has access to my data?

Only Patricia Galvin, Speech and Language Pathologist has access.

Who do you share my data with?

When providing healthcare, it is considered good practice to keep other people involved in your care updated. I may share your information with any of the following: your family/carer/friend, your G.P or Medical Consultant, another SLT or healthcare professional involved in your care, and only with your permission. I will ask your permission before sharing your information with other people. The exceptions to this are if I are required to share the information by law, or I consider you to be at risk by not raising my concerns (e.g. legislation around issues of adult safeguarding).

Patricia Galvin, Speech and Language Pathologist will never sell or loan information about you to 3rd party service providers and your data will not be exported outside of Ireland. The only exception to this would be if you live abroad and give consent for this to happen.

How long do you keep data about me?

Professional guidelines require all Speech & Language Therapists (Independent or within the HSE) to retain clinical files and work diaries (containing contact information) for a period of 7 full years after discharge from our care. This is helpful if you need further treatment at a later date, but is also a requirement in case of litigation.

Duplicate data (which also appears in your SLT file) such as your telephone number and email address will be deleted from electronic devices wherever possible when you are discharged to reduce the possibility of a data breach if such devices are lost or stolen.

The above requirements mean that your 'right to be forgotten' under GDPR law does not apply until I no longer have a need to keep your data for the reasons explained above.

If you make an enquiry about our service but for whatever reason do not get back to us, any written notes of our telephone conversations with you, email correspondence and contact details will be deleted/shredded after a period of 3 months.

How can I access the information you hold about me?

Patricia Galvin, Speech and Language Pathologist will keep you fully informed of every aspect of your care. You will routinely be given copies of any letters or reports which are written about you unless there is a legal reason for us not to do so (e.g. adult safeguarding issues, police investigation, court evidence). You have the right to access your SLT file, but any request to do so must be made in writing. Patricia Galvin, Speech and Language Pathologist reserve the right to charge a fee to cover the administrative cost of providing this information.

 

What happens if there is a breach of data about me?

Patricia Galvin, Speech and Language Pathologist is required to inform you if the data breached about you could negatively affect your personal or professional life and is considered 'a threat to your rights or freedoms'. I must also inform the Office of the Information Commissioner within 72 hours of discovering such a breach.

If you feel that your data protection rights have been breached by Patricia Galvin, Speech and Language Pathologist, you should raise your concerns with me in the first instance and I have 28 days in which to respond to your concerns. If you still feel that your concerns have not been satisfactorily addressed by me, you have the right to lodge an official complaint to the Office of the Information Commissioner.

 

Changes to my privacy policy

I keep our privacy notice under regular review and will update you accordingly.

Further information

Please contact me if you have any questions about my privacy policy and how it applies to the information I hold about you.

Patricia Galvin 087 7109873     pgalvin@hermitageclinic.ie